SINGAPORE Law and Practice Contributed by: Lim Chong Kin, Drew & Napier LLC
(b) the loss of any storage medium or device on which personal data is stored. Specific Categories of Personal Data While the PDPA does not define “sensitive” per - sonal data nor prescribe different legal bases for its collection, the PDPC has taken the position that certain types of personal data (eg, personal data of a financial nature such as bank account details, personal data of minors and health and medical information) should be safeguarded by a higher level of protection so as to constitute “reasonable security measures” under the PDPA (Re Aviva Ltd [2017] SGPDPC 14). 5. Audiovisual Media Services 5.1 Requirements and Authorisation Procedures Regulation of the Media Sector Similar to telecommunications, the IMDA is also responsible for the regulation of the media sec - tor (including broadcasting and film). “Media” is defined in the IMDA Act as: • a film, as defined in the Films Act 1981 (FA); • a newspaper, as defined in the Newspaper and Printing Presses Act 1974; • a broadcasting service, as defined in the Broadcasting Act 1984 (BA); • a publication, as defined in the Undesirable Publications Act 1967; or • such other medium of communication of information, entertainment or other matter to the public (or a section of the public) as the Minister may specify by order in the Gazette. Generally, the provision of audiovisual services in or from Singapore (eg, TV or radio) would be regulated under the BA, and the IMDA may grant a broadcasting licence for the provision of:
• free-to-air nationwide, localised and interna - tional television services; • subscription nationwide, localised and inter - national television services; • special interest television services; • free-to-air nationwide, localised and interna - tional radio services; • subscription nationwide, localised and inter - national radio services; • special interest radio services; • audiotext, videotext and teletext services; In addition, the BA provides for a class licensing regime, under the Broadcasting (Class Licence) Notification and Broadcasting (Class Licence – Broadcasting to Digital Display Panels) Notifica - tion 2020, for: • virtual area network computer online services; • computer online services that are provided by internet content providers and internet service providers (ISPs); and • distribution network digital display panels services. • video-on-demand services; • broadcast data services; and • computer online services. In particular, it should be noted that “internet content providers” is broadly defined under the Broadcasting (Class Licence) Notification to include any individual in Singapore who provides any programme, for business, political or reli - gious purposes, on the World Wide Web through the internet, as well as any corporation or group of individuals (whether registrable or incorpo - rated under Singapore law or not) that provides any programme on the World Wide Web through the internet. In such cases, it is possible that companies operating video-sharing platform services on
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